further information is available in the information for ... · pdf fileincurred cost...
TRANSCRIPT
Incurred Cost Submissions Further information is available in the Information for
Contractors Manual under Enclosure 6
The views expressed in this presentation are DCAA's views and not necessarily the views of other DoD organizations
Incurred Cost Submissions Due Dates of Submissions Delinquent Submissions Adequacy Review Audit Requirements Required Submission Schedules ICE Model Penalties Frequently Asked Questions
2
Due Dates of Submissions Incurred cost claims are due six months after completion of the contractor’s fiscal year end.
Per the Allowable Cost and Payment Clause (FAR 52.216-7(d)(2)) Allowable cost and payment clause applies to cost-reimbursement type contracts (FAR 16.307)
3
Delinquent Submissions If submissions are six months delinquent, DCAA will recommend a decrement factor and for the CO to make a unilateral determination. (FAR 42.703-2(c)(2))
4
Incurred Cost Adequacy Review We check for the schedules listed FAR 52.216- 7(d)(2)(iii) Any missing or unreconcilable schedule could cause us to report the submission as inadequate. Recommend self-assessment
http://www.dcaa.mil/incurred_cost_checklist.html
5
Audit Requirements FAR 31.201-2 (d) Requires contractors to maintain records and supporting documentation to demonstrate allowability and allocability of costs. FAR 31.205 also requires specific documentation to demonstrate the allowability of certain cost elements
6
Examples of Specific Documentation Under FAR 31.205
FAR 31.205-33, Professional and Consultant Service Costs, requires the following evidential matter:
Details of all agreements (e.g., work requirements, rate of compensation, and nature and amount of other expenses, if any) with the individuals or organizations providing the services and details of actual services performed; Invoices or billings submitted by consultants, including sufficient detail as to the time expended and nature of the actual services provided; and Consultants’ work products and related documents, such as trip reports indicating persons visited and subjects discussed, minutes of meetings, and collateral memoranda and reports.
7
Examples of Specific Documentation Under FAR 31.205
FAR 31.205-46, Travel Costs indicates costs shall be allowable only if the following information is documented:
Date and place (city, town, or other similar designation) of the expenses; Purpose of the trip; and Name of person on trip and that person’s title or relationship to the contractor
8
ICE MODEL ICE is an EXCEL spreadsheet that provides
contractors with a standard user-friendly electronic package to assist in preparing
timely and adequate incurred cost submissions.
It should result in less time being spent in: Submission preparation. Supporting the audit.
9
ICE BENEFITS • User Friendly
• It includes all schedules required for an adequate submission per FAR 52.216-7
• Updates are performed electronically and the linking feature updates all impacted schedules.
• ICE creates an inventory of electronic files that can be used in subsequent years to compare costs and facilitate submission preparation.
• The submission of an adequate proposal may expedite contract closings.
10
Required Information in Incurred Cost Submission FAR 52.216- 7(d)(2)(iii) (referenced to ICE model)
Schedule A Summary of Indirect Expense Rates Schedule B, C, D Indirect Cost Pools
Schedule E Claimed Allocation Bases Schedule F Cost of Money Schedule G Booked and Claimed Direct Costs Schedule H Direct Costs by Contract at Claimed Rates Schedule H-1 Government Participation by Pool Schedule I Schedule J Schedule K Schedule L Schedule M Schedule N Schedule O
Cumulative Allowable Cost Worksheet Subcontract Information Hours and Amounts on T&M Contracts Payroll Reconciliation Accounting/Organization Changes Certificate of Indirect Costs Contract Closing Information
11
Schedule E—Claimed Allocation Bases
PER G/L, F/S PER G/L Overhead & TRIAL BAL/FSADJUSTMENTS CLAIMED
Overhead Pool $ 543,522 $ (32,912) $ 510,610 Overhead Base:
Total Contract Labor $ 633,012 $ 633,012 IR&D Labor 14,287 14,287 B&P Labor 9,525 9,525 Total Overhead Base $ 656,824 $ - $ 656,824
Overhead Rate 82.75% 77.74%
Overhead Base* - Straight time direct labor dollars of all contracts and projects including labor costs of IR&D/B&P projects.
PER G/L, F/S PER G/L & TRIAL BAL/FSADJUSTMENTS CLAIMED
G&A Pool $ 280,502 $ (9,479) $ 271,023
G & A Base: Contract Labor
$ 633,012 Contract Travel 34,563 Contract Material 842,981 Other Direct Costs 172,105 Subcontracts 944,841
Subtotal = DIRECT COSTS $ 2,627,502
General Ledger Overhead (before adjustments) Less: IR&D/B&P O/H transferred to G & A pool.
543,522
IR &D O/H (at G/L rate) (11,822) B&P O/H (at G/L rate)
Other Misc Adjustments to G&A Base (provide detailed support) (7,882)
- G&A Base - Total Cost Input (exludes IR&D/B&P and COM) $ 3,151,320
G&A Rate 8.60%
14
Schedule F—Facilities Cost of Money
NBV BASES 1. Applicable 2. Accumulation 3. Allocation of 4. Total Net 5. COM for Cos 6. Allocation 7. Facilities
Company 1 Cost of Money & Distribution of Undistributed Book Value Accounting Base For Capital COM Cost Accounting Period 20xx Rate NBV Period Period Factors
Business Unit
Facilities Capital
Recorded 5.16% 69,761 (Basis Of Allocation) (Column 2+3) (Column 1*4) In units (Column 5/6) of measure Leased Property 162,290
Corporate/Group (Note 1) Total 232,051 Undistributed 193,290 Distributed 38,761
Overhead Pools
Cost of Money Overhead 30,345 168,162 198,507 10,237 656,824 0.01559 Unused - - - - - 0.00000 Unused - - - - - 0.00000 Unused - - - - - 0.00000 Unused - - - - - 0.00000 Unused - - - - - 0.00000 LESS: COM on IR&D/B&P Labor: Cost of Money Overhead (371) (23,812) 0.01559 Unused - - 0.00000 Unused - - 0.00000 Unused - - 0.00000 Unused - - 0.00000 Unused - - 0.00000
Subtotal 9,866 G&A Expense Pools
G & A 8,416 25,128 33,544 1,730 ADD: COM on IR&D/B&P Labor 371 Subtotal: 2,101 3,151,320 0.00067
TOTAL 38,761 193,290 232,051 11,967
Note 1 Allocation Bases (Refer to Schedule E for details) Overhead COM: Straight time direct labor dollars of all contracts and projects including labor costs of IR&D/B&P projects. G&A COM: Total cost input (excluding G&A, B&P, and Cost of Money)
15
Computing COM Rate: Treasury
Rate M os. COM Rate Apr - Jun 08 4.750% 3.00 1.188% Jul - De c 08 5.125% 6.00 2.563% Jan - M ar 09 5.625% 3.00 1.406%
5.157% Months percentage added for demonstration purposes - adjust as needed
Schedule H—Direct Costs by Contract at Claimed Rates
Total Claimed Direct G&A Claimed
O/H G & A JOB Prime SUBCONTRACT Labor Total Sub- Direct O/H Costs Plus Base G &A Total COM COM Total Grand
ORDER CONTRACT NUMBER NUMBER O/H Labor Travel Material ODC Contracts Costs O/H O/H (TCI) Applied Costs Applied Applied COM Total A. COST TYPE(no entry on title line)
-
-
-
-
-
-
-
-
-
-
373,954 94,931 468,885 468,885 40,324 509,209 1,904 314 2,218 511,427
4,870 - 4,870 4,870 419 5,289 - 3 3 5,292
34,088 12,739 46,827 46,827 4,027 50,854 255 31 286 51,140
A. TOTAL COST TYPE: 147,473 147,473 7,841 125,067 48,657 111,141 440,179 114,646 554,825 554,825 47,715 602,540 2,159 348 2,507 605,047 B. OTHER FLEXIBLY PRICED (Note 3) 89,732 407,232 163,497 570,729 570,729 49,083 619,812 3,279 382 3,661 623,473
- - - - - - - - - -
- - - - - - - - - - B. TOTAL OTHER FLEXIBLY PRICED 210,312 210,312 8,932 38,643 59,613 89,732 407,232 163,497 570,729 570,729 49,083 619,812 3,279 382 3,661 623,473 C.. VAR. TIME & MAT'L - - - - - - - - - -
6,682 4,120 10,802 10,802 929 11,731 83 7 90 11,821
3,803 2,240 6,043 6,043 520 6,563 45 4 49 6,612
- - - - - - - - - -
3,832 2,263 6,095 6,095 524 6,619 45 4 49 6,668 C.. TOTAL VAR. TIME & MAT'L 11,093 11,093 974 2,250 - - 14,317 8,623 22,940 22,940 1,973 24,913 173 15 188 25,101
D. VAR-FIXED PRICE 147,318 282,113 77,599 359,712 359,712 30,935 390,647 1,556 241 1,797 392,444
- - - - - - - - - -
- - - - - - - - - -
- - - - - - - - - - D. TOTAL VAR-FIXED PRICE 99,819 99,819 5,338 16,724 12,914 147,318 282,113 77,599 359,712 359,712 30,935 390,647 1,556 241 1,797 392,444
E. VARIOUS COMMERCIAL WORK 596,650 1,483,661 127,738 1,611,399 1,611,399 138,580 1,749,979 - - - 1,749,979
- - - - - - - -
- - - - - - - - E. TOTAL VARIOUS COMMERCIAL WORK 164,315 164,315 11,478 660,297 50,921 596,650 1,483,661 127,738 1,611,399 1,611,399 138,580 1,749,979 - - - 1,749,979
TOTAL CONTRACT COSTS 633,012 633,012 34,563 842,981 172,105 944,841 2,627,502 492,103 3,119,605 3,119,605 268,286 3,387,891 7,167 986 8,153 3,396,044
24,011 35
7,405 23 TOTAL IR & D/B & P 23,812 610 211 15,388 - 40,02 18,512 58
GRAND TOTAL
656,824
35,173
843,192
187,493
944,841
2,667,523
510,615
17
1201 N00039-90-C-0873 - Claimed 122,113 122,113 5,231 115,068 43,630
Not Claimed (note 1) - 1,687 3,183 1203 N00040-90-C-0874 16,387 16,387 836 312 1,212 1204 Subcontract-Clark Inc. 8,973 8,973 87 9,687 632
87,912
15,341 7,888 27,267 6,976 34,243 34,243 2,945 37,188 (Note 2) (Note 2) - 37,188
1205 N000060-90-C-0913 210,312 210,312 8,932 38,643 59,613
- - 1301 N00022-96-D-0111 - Task Order No. 1 5,300 5,300 382 1,000 Task Order No. 2 2,882 2,882 421 500 1305 F66777-97-D-0112 - Task Order No. 1 2,911 2,911 171 750
99,819 99,819 5,338 16,724 12,914
- - -
164,315 164,315 11,478 660,297 50,921
- -
IR & D 14,287 14,287 366 126 9,232
B& P 9,525 9,525 244 85 6,156
Schedule H-1—Government Participation
Ove rhe ad
Overhead G&A Contract Type Base Amount % Base Amount % Cost-Type 147,473 22.5% 554,825 17.8% Flexibly Priced 210,312 32.0% 570,729 18.3% T&M 11,093 1.7% 22,940 0.7% Fixed Price 99,819 15.2% 359,712 11.5% Commercial 164,315 25.0% 1,611,399 51.7% IR&D/B&P 23,812 3.6% - 0.0% Total 656,824 100.0% 3,119,605 100.0%
Note : The purpose of this schedule is to present a general overview of the extent that cost-type
and flexibly priced contracts participate in the absorption of indirect expenses
18
Schedule I—Cumulative Direct and Indirect Cost Claimed and Billed
Unsettled/Claimed Direct And Indirect
Costs Using Claimed
Cumulative Billed (Manual Entry)
Order
Subject To
Penalty Clause
Prior Years
Settled Total Costs
Prior Year Costs FYE
Current Year
Costs FYE
Total Cumulative Settled or Claimed
Less Contract
Limitations Rebates/
Credit
Net Cumulative Settled or Claimed
PV No.
Date Cost Billed
Through Amount
Over (Under) Billing
Physically Complete
Contract No. Subcontract No. No. Note (2)
Note (3) Note (4) Note (4) Note (5) Note (6) (Note 7)
Cost Type & Flexibly Priced: (note 1) N00039-90-C-0873
1201 Yes
126,821 511,427 638,248
638,248 18 2/28/2009 640,110 1,862 N00040-90-C-0874
1203 Yes 382,595 2,867,500 51,140 3,301,235
3,301,235 30 3/31/2009 3,295,110 (6,125)
Sub. Clark Inc. 1204
359,626 555,311 37,188 952,125
952,125 24 1/31/2009 960,100 7,975 Yes N000060-90-C-0913
1205 Yes 591,362 443,916 623,473 1,658,751
1,658,751 33 3/31/2009 1,640,426 (18,325) Yes
Subtotal-Cost & Flexibly Priced Contracts
6,550,359
6,550,359
6,535,746 (14,613)
Time & Material N00022-96-D-0111
001
10,601 10,601
10,601 6 12/31/2008 10,848 247 Yes N00022-96-D-0111
002
5,950 5,950
5,950 6 12/31/2008 5,000 (950.00)
F66777-97-D-0112
001
6,000 6,000
6,000 2 12/31/2008 5,750 (250.00)
Subtotal Time & Material Contracts
22,551
22,551
21,598 (953.00)
Total Cost-Flexibly Priced and Time & Material Contracts
6,572,910
6,572,910
6,557,344 (15,566)
19
Schedule J—Subcontract Information
Subcontracts issued under flexibly priced prime contracts – Yes _X No
SUBCONTRACT NO.
PRIME CONTRACT NO. SUBCONTRACTOR'S
NAME & ADDRESS POINT OF CONTACT
AND PHONE NO. SUBCONTRACT
VALUE Performance Period INCURRED
IN FY 2009 AWARD
TYPE From To
Subcontracts Issued:
N00039-05-C-0873
Small Company
Ms. Donna Charleston
$110,500
3/16/2006
6/30/2009
$87,912
CPFF P.O. #XYZ0998R
1445 Southpark Blvd. Marketing Manager Buffalo, NY 14206 (716) 883-8700 X317 P.O. #XYZ0776R
N00040-05-C-0874
Tanza Enterprises
Mr. Mike Tanza
$895,000
4/20/2006
12/2//2010
$15,341
CPFF
87B Executive Park President Fairfax, VA 22033 (703) 983-5640 P.O. #XYZ01032R
Subcontract to Clark Inc.
Argonautics, Inc.
Mr. Ted Kessel
$152,500
7/25/2008
10/16/2011
$7,888
CPFF
Prime N00039-05-C-0875 555 Ocean Parkway Marketing Manager Anaheim, CA 92803 (714) 998-2000 X12 P.O. #XYZ1213R
N00060-05-C-0913
DSK Corporation
Ms. Jane Matthews
$236,135
10/12/2008
3/15/2009
$49,732
CPFF
3559 Vaulting Road Marketing York, PA 17405 (717) 992-7800 P.O. #XYZ0822R
N00060-05-C-0913
Aristeo Associates
Mr.Vince Aristeo
$100,000
5/14/2007
5/14/2008
$40,000
CPFF
546 Arroyo Drive President Carlsbad, NM 87112 (504) 535-1600
Schedule K—Hours and Amounts on Time and Material (T&M) Contracts
This Schedule is linkedto schedule A for the G&A rate. SCHEDULE K Any changes in data will affect Schedule I. ICE (version 2.0.1c) Other than G&A rate, only manual or externally imported entries Schedule A - Applied Overhead, G&A, & COM Rates XYZ Corporation NOTE: Hidden rows have been inserted that will allow for automatic adjustment of the column totals when additional rows are inserted
Contract Labor Contract No. 22-96-D-0111 Contract No. 22-96-D-0111 Contract No. 77-97-D-0112 Contract No. Contract No. Category (1) Task: 001 Task: 002 Task: 001 Task: Task:
LABOR Rate (2) Hrs Amount Rate (2) Hrs Amount Rate (2) Hrs Amount Rate (2) Hrs Amount Rate (2) Hrs Amount Program Manager $ Senior Engineer $ Engineer $ Analyst $ Technical Typist $
25.00 20.00 15.00 12.50
7.00
100 2,500 $25.00 50 1,250 $22.50 100 2,250 - - 100 2,000 $17.50 100 1,750 $17.50 100 1,750 - - 200 3,000 $12.50 100 1,250 $16.00 50 800 - - 100 1,250 $12.50 - - $10.00 20 200 - -
50 350 $7.00 100 700 $0.00 - - - - TOTAL 550 9,100 350 4,950 270 5,000 - - - -
OTHER COSTS Material Costs (3) 1,000 500 750 - -
Travel Costs (3) 382 421 171 - - Sched A
G&A @: 8.60% (4) 119 79 79 - - Subtotal 1,501 1,000 1,000 - -
TOTAL 10,601 5,950 6,000 - -
Task Ceilings 25,000 12,500 7,500
Explanatory Notes
(1) Represents effort performed by the company. Any subcontract effort should be identified separately. (2) Represents rates specified in the contract which may be higher or lower than actual rates incurred. (3) Represents actual costs recorded in the cost records. (4) G&A applied at the claimed rate to Material (if not Value-added base) and Travel Costs.
21
Schedule L—Payroll Reconciliation Reconciliation of Total Payroll per IRS form 941
to Total Labor Costs Distribution Fiscal Year End - 3/31/2009
NOTE: Hidden rows have been inserted that will allow for automatic adjustment of the column totals when additional rows are inserted NOTE: Links not established for indirect costs because they have to be linked to account numbers inserted by contractor.
General
Description Le dge r Re fe re nce
Dire ct Labor 656,824 Summary SCHED H Ge ne ral & Administrative : SCHED B
Salaries 90,007 Holiday Wages 2,321 Vacation Wages 5,812 Sick Leave 987 Personal Absence 1,082
Ove rhe ad Pools: SCHED C (x) Wages 33,060 Holiday Wages 20,181 Vacation 25,440 Sick Leave 14,318 Severance Pay (in full) 32,419
Intermediate Pools: Occupancy Wages 23,280 SCHED D (x) Overtime Premium (in ODCs) 270 Overtime Premium - Other Adjustment to arrive at Total Payroll Distributed (Provide detailed support)
-
TOTAL LABOR DISTRIBUTION 906,001
22
Schedule M—Accounting/Organization Changes, etc.
This schedule provides information to the auditor related to the following:
Significant decisions, agreements or approvals (e.g. pension plan, billing rates or contract ceilings) Significant accounting or organization changes (e.g. changes to indirect pool structure or mergers and acquisitions)
23
Schedule N—Certificate of Indirect Costs Certificate of Final Indirect Costs
Fiscal Year End - 3/31/2009
This is to certify that I have reviewed this proposal to establish final indirect cost rates and to the best of my knowledge and belief:
1. All costs included in the proposal (ide ntify proposal and date ] to establish final indirect cost rates for (ide ntify pe riod cove re d by rate ) are allowable in accordance with the cost principles of the Federal Acquisition Regulation (FAR) and its supplements applicable to the contracts to which the final indirect cost rates will apply; and
2. This proposal does not include any costs which are expressly unallowable under applicable cost principles of the FAR or its supplements.
Firm:
Signature:
Name of Certifying Official:
Title:
Date of Execution:
FAR Part 52.242-4-- Certification of Final Indirect Costs. As prescribed in 42.703-2(f), insert the following clause:
Certification of Final Indirect Costs (Jan 1997) (a) The Contractor shall -- (1) Certify any proposal to establish or modify final indirect cost rates; (2) Use the format in paragraph (c) of this clause to certify; and (3) Have the certificate signed by an individual of the Contractor's organization at a level no lower than a vice president or chief financial officer of the business segment of the Contractor that submits the proposal. (b) Failure by the Contractor to submit a signed certificate, as described in this clause, may result in final indirect costs at rates unilaterally established by the Contracting Officer. (c) The certificate of final indirect costs shall read as follows: (see above)
24
Schedule O—Contract Closing Info
Ready Performance Period To Contract Ceiling
Level of Effort Cumulative Hours
Contract No. Order No From To Close(1 Amount (2) Fee(3) Required Actual Notes
Cost Type:
Subcontract-Clark Inc. 2/16/05 2/28/09 Yes 1,000,000 60,000 15,000 14,588 N00060-95-C-0913 10/16/06 12/28/08 Yes 1,750,000 112,000 27,500 28,950
Time & Material N00022-96-D-0111 001 7/1/06 12/31/08 Yes 25,000
25
Preparation Notes: (1) Indicate whether the contract is ready to close based on all information available. If the contract is not ready to close (e.g., a contract modification is being pursued), the reasons why should be stated in a footnote: (2) Provide the overall contract ceiling amount before fee, for the type of contract. (3) Provide fee amount as provided by the contract. Include details of the fee computation for all flexibly priced incentive fee and level of effort type contracts, along with the contract modification used, in a footnote.
EXPLORING ICE MODEL
ICE MANUAL.DOC Complete Instructions for Using the ICE
Model
27
EXPLORING ICE MODEL Includes Two Excel Files :
ICE_Model(2.0.1c).xls - Template for Use in Preparing Incurred Cost Proposal ICE_Demo(2.0.1c).xls – Sample File with
Data
28
Other Schedules Provided by ICE The ICE program provides the following additional Schedules:
Comparative Analysis by pool and account Reconciliation of claim to corporate income tax return Contract Brief Executive Compensation form
29
Penalties (FAR 42.709): Penalties will be assessed if a contractor claims an expressly unallowable indirect costs (as noted in FAR 31.2) in an incurred cost submission Two levels of penalties
30
Common Deficiencies:
Signed certification not included or not signed by at least a Vice President or CFO (schedule N) Lack of subcontractor information (schedule J) Not all intermediate allocations disclosed (sch. D) Unallowable costs not included in G&A base (sch. E) IR&D/B&P not fully burdened (sch. B) Physically complete contracts not shown on sch. I & O Government participation not calculated for all final indirect rates (schedule H-1)
31
Frequently Asked Questions: Do I have to use the ICE model?
No, contractor may use any format; However, the ICE model does provide all the schedules required per FAR 52.216-7
32
Frequently Asked Questions: Can DCAA grant an extension for submitting my final incurred cost rate proposal?
No. Extensions for submitting final rate proposals can only be granted by the administrative contracting officer per FAR 42.302 and FAR 42.705-1(b)(1)(ii). To locate your responsible administrative contracting officer, please contact the Defense Contract Management Agency (DCMA).
33
Frequently Asked Questions: When will DCAA determine adequacy of my incurred cost submission and perform the incurred cost audit?
Auditors should evaluate a contractor’s incurred cost proposal upon receipt and immediately notify the contracting officer of significant deficiencies. It is DCAA policy that indirect submissions will be audited as promptly as possible after receipt.
34
Frequently Asked Questions: I’m preparing my submission(s) (e.g. contract pricing proposal, forward pricing rates, incurred cost, etc.) and would like to ask the DCAA auditor some specific questions on my submission to make sure I’m on the right track. Will the DCAA auditor give me some specific advice on how to prepare my submission?
Answer: A DCAA auditor can answer general questions related to the acquisition regulations. For example, if a contractor asked advice on what the FAR requires in certain situations, a DCAA auditor would be able to provide that information. Auditors may also provide general advice on what constitutes an adequate submission. However, auditors are precluded from assisting contractors in preparing and developing the contractor’s submission because doing so would create a significant threat to the auditor’s independence. Contractors should look under the “Guidance” and “Checklist and Tools” tabs on DCAA’s website for guidance about the adequacy of their specific submission.
35